Securing UK Soil Heath


POSTNOTE
Number 502 August 2015
Securing UK Soil Health
Overview
2015 is the United Nations International Year of
Soils. Soils underpin the global food system and
regulate water, carbon and nitrogen cycles but
are subject to pressures from population growth
and climate change. In England & Wales, soil
degradation costs around £1bn per year. This
POSTnote outlines the evidence for measures
that sustain soils and existing policies affecting
soil health.
Background
Soil performs several globally important functions:
 Around 95% of food production relies on soil.1 The global
nature of the food system makes soil health (or quality)
an international concern.
 Soils are home to a quarter of the Earth’s biodiversity;
organisms such as bacteria, fungi, and earthworms.
These support plant growth, and cycle carbon, nitrogen
and other nutrients. Soil microbes are a source of
antibiotics and may provide future drug discoveries.2
 Soils absorb and store water; their capacity to do so relies
on good soil structure, which is maintained by soil
organisms, organic matter and appropriate
management.3,4
 Soils store three times as much carbon as is contained in
the atmosphere; degradation of carbon-rich soils releases
significant quantities of CO2.5
The ability of soil to perform these functions is reduced
when it is degraded (its quality is reduced) or eroded (its
quantity is reduced). There may be trade-offs between the
different functions of soil; for example, increasing food
production can be detrimental to water quality (POSTnote
478), carbon storage and biodiversity.6-8 Over half the
world’s agricultural land is subject to soil erosion (reduction
in soil depth) and 12m hectares are abandoned each year
because of soil degradation due to unsustainable farming
 Soils filter and store water, support
agriculture and other plant and animal
communities, and harbour a quarter of the
world’s biodiversity.
 Soil is a renewable resource but can be
permanently degraded by pressures such as
urbanisation or erosion. Degradation of peat
soils releases CO2 to the atmosphere.
 Arable soil health can be improved by
appropriate cropping and organic matter
inputs but poor management can lead to
erosion, degradation of soil fertility and
reductions in water-holding capacity.
 The evidence base for soil management has
been challenging to develop because soils
improve slowly. There is no UK-wide
scheme for monitoring soil health.
practices.9 Nutrient deficiencies in soil can directly affect
human diet and health.10 In 1982, the UN Food & Agriculture
Organisation World Soil Charter called for governments to
commit to “manage the land for long-term advantage rather
than for short-term expediency”. Since then, many reports
have highlighted the problem of ongoing soil degradation
and its implications for global food security.11-13 Protecting
soil presents an opportunity to address simultaneously
several global challenges such as food security, climate
change, water security, waste management and biodiversity
loss.12,13
This note summarises the most common soil degradation
processes globally, then focuses on soil degradation in the
UK, management strategies to improve soil health, and the
policies affecting UK soils. Agricultural land occupies 75% of
the UK and 10% is urban and developed.14
Soil Degradation
Many processes of soil degradation are associated with
food, forestry, textile and biofuel production, so pressures
on soil may be exacerbated by the demands of rising
population. Soil erosion is also likely to be aggravated in the
future by heavier winter rainfall events2 and there may also
be indirect effects on soil associated with climate-induced
changes in land use.15,16
The Parliamentary Office of Science and Technology, 7 Millbank, London SW1P 3JA T 020 7219 2840 E [email protected] www.parliament.uk/post
POSTnote Number 502 August 2015 Securing UK Soil Health
Mechanisms of Soil Degradation
 Sealing by infrastructure – building and urbanisation
often covers soil with water-impermeable surfaces. All
functions are lost from sealed soil; for example, water
run-off to surrounding land is increased (POSTnote 448).
Agricultural land is often used for urban expansion.
 Compaction – the weight of farm machinery or livestock
can compress soil which increases water run-off, reduces
water holding capacity and makes it harder for plants to
grow (POSTnote 484).4,17 In arable soil, cultivation
becomes more difficult so fuel costs and machinery wear
increase. Compaction is more common under crops that
are cultivated or harvested when soil is wet. Remediating
deep compaction can be difficult and requires costly
machinery. Vehicle compaction can be reduced by using
satellite positioning to keep vehicles to fixed routes in
fields (Controlled Traffic Farming; POSTnote 505).
 Loss of organic matter (OM) (Box 1) – cultivation and
removal of crop residues can reduce the OM content of
soil.3,18,19 This impairs most soil functions, reduces fertility
and water holding capacity and leaves soils vulnerable to
erosion and compaction.13,20 Soils such as peat contain
large stores of carbon as OM, accumulated over millenia
under waterlogged conditions. Draining these soils for
agriculture or forestry can cause this carbon to be
released to the atmosphere as CO2.5
 Erosion – wind or water can physically remove soil,
leading to sediment run-off to drainage channels
(POSTnote 484) and reduced fertility.6,9,17 Soils can
become unproductive and eventually be lost entirely.
Some crops (maize, sugar beet, potatoes) are more
prone to soil erosion than others because they establish
slowly (leaving soil bare for longer after planting) or
require extensive disturbance of soil during cultivation.21
 Contamination – toxic elements, such as arsenic, can
accumulate in soil often as a result of industrial activity.
Contamination can damage biodiversity, make soil nonproductive and pollute underlying groundwater. Methods
to remediate severe contamination are expensive.
 Salinisation – irrigation water or coastal flooding that
evaporates leaves salts, which can build up in soil to
levels that reduce fertility or are toxic for plants, and is a
major cause of desertification. Globally, a third of food is
grown on irrigated land. Although expensive, salinisation
can sometimes be alleviated using large volumes of
purified water.
 Acidification – atmospheric pollutants produced by fossil
fuel burning, industry and agriculture can increase the
acidity of rain, which may alter soil chemistry and biology
to reduce soil fertility. Draining wetlands, coniferous
forestry and nitrogen fertilisers can contribute to the
acidification of some soils.22
UK Soils
The UK has over 700 soil types, determined by variations in
geology, climate, plant and animal ecology and land use.
The UK’s young soils (due to relatively recent glaciation)
and mild climate mean that degradation is not currently as
problematic as in some countries, but soil degradation costs
are still significant (Box 2). For example, agricultural soils
can be subject to erosion, compaction and loss of OM.18 UK
Page 2
Box 1. Soil Carbon and Organic Matter Amendment
Soil carbon content is usually defined by the amount of organic matter
(which is around 50% carbon). Data from the Countryside Survey
1978-2007 show that arable agriculture tends to deplete soil carbon.18
Adding organic matter (OM) to arable soil has many benefits,
including:
 providing nutrients for plants and soil organisms, which improves
natural soil functioning and reduces the need for synthetic
fertiliser23,24,25
 improving the structure of soil, which makes it less vulnerable to
erosion and better able to hold water and reduce flood risk20
 adding carbon, making better use of soil carbon storage capacity
 reducing soil density, which saves fuel during ploughing and
reduces wear on agricultural implements.23
Regular addition of OM in combination with fertiliser inputs over
several years results in improved yields and reduced farm costs. OM
can be derived from plant material, food and industrial waste,
compost, sewage sludge and animal manures. Regular application is
as important as the type of organic material added.23
cereal yields are still among the highest in the world (6-7
tonnes per hectare)26 but after many years of increasing
yields, the last eight years have seen a wheat yield plateau
(POSTnote 418).27 In some areas cultivation has led to
severe soil damage (Box 3). There are also thousands of
potentially contaminated sites in the UK.28 Salinisation may
also become a problem in low lying parts of the UK in the
future.
In England, 10% of soil is in urban areas and is subject to
high levels of sealing.14 Growth in housing will exacerbate
this pressure. In Northern Ireland, building on agricultural
and semi-natural land has increased. Conversion of seminatural habitats to agricultural grassland, scrub or woodland
is reducing biodiversity and there are over-grazing problems
on heath and bog. Damage because of peat extraction is no
longer widespread but still occurs.29 Wales has 3% arable
land and large areas of grassland grazing. The main issues
are compaction on grassland caused by overgrazing, and
the restoration of drained organic soils. Wales also has
1,300 former metal mining sites, some of which have
polluted soils and rivers.28 Scotland has large areas of
upland carbon-rich soils, including extensive peatlands,
which are particularly vulnerable to climate change
impacts.30
Peat Soils
Peat Soils cover 10% of the UK land area but store around
half (5bn tonnes) of the UK’s soil carbon.2 Upland peats
occur in all the UK nations; they provide drinking water and
their degradation can increase flood risk (POSTnote 396).
Lowland peats such as the Fens of East England account
for around a tenth of UK peat and having been drained for
cultivation are some of the UK’s most productive agricultural
land (Box 3). Large areas of UK peat (as much as 80% by
one estimate5) have been adversely affected by landmanagement activities including agricultural drainage and
intensification of grazing, managed burning for grouse
rearing, conifer afforestation and peat extraction.35,36 Peat
areas that are not Sites of Special Scientific Interest (about
two thirds of UK peats) are generally not covered by
restoration schemes and are at risk of further damage.35
POSTnote Number 502 August 2015 Securing UK Soil Health
Box 2. Costs of Soil Degradation in England and Wales
A 2012 report for Defra estimated the annual costs of soil degradation
in England and Wales at between £0.9 and £1.4 billion (Figure 1),
80% of which is due to compaction and loss of soil organic matter.33
Most of these costs are borne not at the site of soil degradation but
elsewhere. For example, the contribution of damaged soils to flooding
events is estimated to be £233m per year, with the total annual cost of
flooding estimated to be £1b (POSTnote 484). There are proven
financial and environmental gains in protecting and improving soil
health, in particular by improving the environmental performance of
farming, restoring peatlands, and planting woodland.34
600
Million £
300
200

GHG
emissions

500
400
Page 3
Agricultural
costs and
productivity
loss
Flooding
100
0
Water
quality
Other

Figure 1. Annual costs of soil degradation in England & Wales.33
Improving Soil Health
Historically, there have been successful initiatives to
improve soil condition, such as the US Government Soil
Conservation Service formed to resolve the ‘dust bowl’ soil
crisis of the 1930s. ‘Terra Preta’ soils in the Amazon Basin
were improved thousands of years ago by adding charcoal
and organic matter and are still exceptionally fertile.37
Soil Management Strategies
Soils vary on national, regional and field scales and
optimum management practices will vary from place to
place, depending on soil type, land use and climate.
Possible measures include:
 OM addition to agricultural land confers benefits on
most aspects of soil health (Box 1). Adding OM can
increase soil carbon content for up to 20 years before it
plateaus. It can be several years before benefits are
apparent in crop yields or farm profits.6,9,17,20,23-,25,38
 Cover crops (or green manures), such as clover and
vetch, protect soil from erosion and nutrient leaching over
winter (POSTnote 478) and can be tailored to suppress
Box 3. Areas with Degraded Agricultural Soils
East Anglian Fens
Parts of the East Anglian fens have been drained to grow crops and
the carbon-rich peat soil is being lost at rates of 1-2 cm a year. Since
the mid-19th Century, 84% of East Anglian peat has been lost21 and in
some places, peat soils that were four metres deep have entirely
disappeared.31 Restoring the water-table level of some cultivated fens
may provide more economic benefits than the existing agriculture.2,21
South-West England
Maize fields are particularly prone to soil compaction and erosion.
Compaction reduces rain infiltration that increases water run-off, and
eroded soil contributes to sediment in river and drainage channels. In
South-West England, where serious flooding has occurred in recent
years, maize cultivation has increased, 75% of maize sites suffer from
soil compaction4,21 and up to half of river sediment may be soil eroded
from maize fields.32

weed growth and improve soil structure. They are then
killed off or ploughed in, adding OM to the soil. Benefits to
soil health vary with crop and weather and can take three
or more years to become apparent.38-40
Longer crop rotation and intercropping. Varied cropping
permits soil recovery and may reduce pesticide
requirement (POSTnote 501). The benefits of increasing
rotation complexity depend on the crop species used.41
Growing two or more crops alongside each other
(intercropping) can suppress pests and weeds, covers the
soil, protecting it from erosion and can increase nutrient
supply to the main crop,42 although mechanical
harvesting can be difficult.
Non-inversion or reduced tillage improves soil
structure, can reduce erosion, cultivation time and fuel
costs, and encourages earthworms. It does not
necessarily sequester carbon (POSTnote 486),6,41 and
may not be suitable for organic farming because
associated weed growth requires pesticide control. A
flexible management approach to tillage, according to
climate and crop, is most financially profitable.38
Tree planting in strategic areas increases water
infiltration and reduces erosion and run-off of sediment
and water (POSTnote 396). Low density forestry can
sometimes be effectively combined with animal grazing.43
However, commercial forestry on upland carbon-rich soils
such as peat can cause significant erosion.
Peat conservation retains soil carbon stores and
minimises CO2 emissions to the atmosphere. Re-wetting
areas previously drained for cultivation restores the plants
(notably Sphagnum moss) and moisture conditions
needed for peat formation, though this can have
implications for methane emissions (POSTnote 454).
Most good soil management practices will have a positive
effect on more than one soil function (Box 1).6,13 Organic
farming certification requires good soil management
practices (such as varied cropping and adding OM) and
organically farmed soils often have higher carbon content,
better structure and greater biological biomass and
diversity.44,45 However, yields are often lower than those
achieved using artificial (fertiliser and pesticide) inputs.46,47
Farming and Soil Management
As in wider society, farmer awareness of soil health, soil
functions and wider issues, such as climate change,
varies.48 In general, knowledge and understanding
generates the confidence to undertake new practices,49 but
profit, ethics, experience, level of support and sense of
community all contribute to farmer decision-making.50,51
Good personal relationships with trusted advisers are likely
to be key to encouraging uptake of good soil management
in many cases,51,52 (such as on remote farms or those
without good access to internet-based information) but there
is a lack of trained, field-experienced, trusted advisers.49
Community partnerships to improve water quality at the
level of river catchments (POSTnote 478) are a good model
for distributing advice to farmers,53,54 but are not nationwide.
Around half of farmers have moved from traditional
ploughing to reduced-tillage cultivation, which can save time
and fuel costs as well as reducing soil compaction and
erosion.21 However, the cost of reduced-tillage equipment
POSTnote Number 502 August 2015 Securing UK Soil Health
(such as seed drills and strip tillers) is likely to prohibit many
from investing in new practices. The equipment needed to
relieve compaction is also costly. The benefits of good soil
management might not be immediate and those farmers on
contracts or short tenancies may have little incentive to
invest financially in safeguarding long-term soil health.
Food Labelling and Soil Management
UK food certification schemes that relate to soil
management include Red Tractor, the LEAF marque and
organic certification. Red Tractor is an industry-led
assurance scheme that requires farmers to comply with
CAP regulations (see below). Both LEAF and organic
standards go further, requiring farmers to manage their soil
to reduce erosion, enhance fertility and maintain good soil
structure in a sustainable and environmentally sensitive
way. Organic standards are defined by EU regulations;
whereas LEAF marque requirements are defined by the
LEAF charity to achieve sustainable farming systems with
high environmental standards. Around 550,000 hectares
(3.2% of UK farmland) is organic certified and 200,000
hectares is farmed to LEAF standards. There is no price
premium on LEAF produce, as there is on organic.
Policy and Evidence
Like other natural assets that provide off-site, non-market
benefits, the economic value of soil is not reflected in
policy.55,11 The evidence base for good soil management
practices has been slow to accumulate because soils
improve slowly and measuring their response needs longterm, controlled studies, of which there are few. Also,
reductions in soil fertility can be compensated for by
increasing the use of artificial fertilisers or irrigation.
Research, Data and Monitoring
Current Research Council-funded projects on sustainable
agri-ecosystems and forecasting the response of soils to
management and climate stress include a centre for
doctoral training (£2.3m), and the SARISA (£5m), SARIC
(£9m plus £1m from industry partners) and Soil Security
(£8m) research programmes. UK soils data are held by
various organisations in the devolved nations. Much is
collated and accessible via the UK Soils Observatory,56 but
some are not publicly available because of privacy or
licensing issues. Most available data relates to geological or
chemical properties of soil. Data on the status of urban soils
are lacking,2 despite the role of soils in the benefits provided
by urban green spaces (POSTnote 448).
The physical and chemical characteristics of UK soil were
monitored 1978 to 2007 by the Countryside Survey (Defra
funding is currently not in place to continue this survey) and
are currently monitored by the Environmental Change
Network (NERC funded). There is currently no UK-wide
monitoring of changes in soil health. Most soil functions are
dependent on living organisms so biological soil quality
indicators (SQIs) are a useful measure of overall soil health.
Because soils and their uses vary widely, a standardised
method of measuring soil health requires a wide variety of
indicators (of genetic, biochemical and functional diversity).
Refining a suite of effective SQIs is an ongoing task.57
Page 4
EU Directives and the Common Agricultural Policy
There is no specific EU legislation on soils. Some EU
Directives have indirectly addressed aspects of soil
management. These include directives relating to water,
nitrates and biodiversity that require reductions in
agricultural run-off of soil and fertilisers to water (POSTnote
478). Consequently, in order to receive Basic Payment
Scheme payments under CAP, UK farmers must maintain
minimum soil cover (with vegetation, crop, cover crop,
stubble or crop residue) and minimise erosion and
compaction (by livestock and vehicle management and
minimising machinery use on wet soil, although there are
exemptions for meeting contractual deadlines).
Requirements for maintaining soil organic matter extend
only as far as not burning stubble. Arable farms must grow
at least two different crops if over 10 hectares, and three if
over 30 hectares.58-61 Compliance with regulations must be
enforced by inspection of at least 1% of farms per year.62
A proposed EU Soils Framework Directive was repeatedly
blocked by some Member States including the UK (with
Austria, Germany, France and the Netherlands) partly
because it proposed a register of contaminated land, which
would have been expensive to compile. However, while
omitting contaminated land, the Scottish Soil Framework
(2009) is similar to the proposed EU directive, aiming to
create a framework for greater connectivity across existing
policy realms relating to soils.30 From 2016, the UK is
required to report to the EU on the systems being developed
to estimate greenhouse gas emissions from farmland, which
must be in place by 2021 (EU Decision No 529/2013).
Soil Policy in England
In England, the 2009 ‘Safeguarding our soils, strategy for
England’63 has been superseded by the Natural
Environment White Paper, which commits government to
ensure soils are managed sustainably by 2030. The Climate
Change Committee has stated that Defra “should take
action to deliver its policy”.21 Defra funding for contaminated
land remediation is being phased out.35 Other existing
policies on soils include:
 the National Planning Policy Framework (2012), which
states that development should preferentially be in areas
of poorer quality agricultural soil64
 Defra’s 2013 Payment for Ecosystem Services (PES)
action plan,65 which identified peat soil restoration as an
area of opportunity, and a pilot ‘UK Peatland Code’ (IUCN
2013), which aims to facilitate sponsorship of peat
restoration.66
 A UK Government strategy aims to reduce horticultural
use of peat to zero by 2030.36
New soil policies in agriculture could be delivered through
existing mechanisms such as CAP payments and
catchment sensitive farming schemes. Current Government
policy is to develop a 25-year plan to “grow more, buy more
and sell more British food”, which would require
improvements in soil health.67
Endnotes
1. UN Food and Agriculture Organisation, 2015, Healthy soils are the basis for
healthy food production.
2. Natural England, 2015, Summary of Evidence: Soils.
POST is an office of both Houses of Parliament, charged with providing independent and balanced analysis of policy issues that have a basis in science and technology. POST is
grateful to Dr Helen Snell for researching this briefing, to the Natural Environment Research Council for funding her parliamentary fellowship, and to all contributors and reviewers.
For further information on this subject, please contact the co-author, Jonathan Wentworth. Parliamentary Copyright 2015. Image copyright istock/©lvenks
POSTnote Number 502 August 2015 Securing UK Soil Health
3. European Commission, 2012, The State of Soil in Europe, JRC.
4. Palmer, R, and Smith, R, 2013, Soil Use and Management, 29 (4) pp. 567-575.
5. IUCN, 2011, Commission of Inquiry on Peatlands
6. Powlson, D, et al, 2011, Food Policy ,36 pp. 72-87.
7. Jones, D, 2013, Journal of Applied Ecology, 50 (4) pp. 851-862
8. Maskell, L, 2013, Journal of Applied Ecology, 50 (3), pp. 561-571.
9. Pimentel, D, 1995, Science, 267, no. 5201, pp. 1117-1123.
10. Yang, X, 2007, Environmental Geochemistry and Health, 29, 413-428
11. Koch, A, 2013, Global Policy, 4 (4) pp.434-441
12. Government Office for Science, 2011, Foresight. The Future of Food and
Farming. Final Project Report.
13. Lal, R, 2010, Food Security, 2, pp. 169-177.
14. Khan, J, 2013, Land Use in the UK. Office for National Statistics.
15. Defra, 2005, Audit of soils-related education and awareness initiatives.
16. Nearing, M, 2004, Journal of Soil & Water Conservation, 59 (1) pp. 43-50.
17. Rickson, R, et al, 2015, Food Security, 7 (2) pp 351-364.
18. Countryside Survey, 2007Soils Report from 2007. CEH.
19. Chapman, S, 2013, European Journal of Soil Science, 64 (4) pp. 455-465.
20. Watts, C, and Dexter, A, 1997, Soil & Tillage Research, 42 pp. 253-275.
21. Committee on Climate Change, 2015, Progress in Preparing for Climate
Change - Report to Parliament.
22. European Commission, Agriculture and Acidification.
23. WRAP, DC-Agri project.
24. Roig, N, et al, 2012, Agriculture, Ecosystems and Environment, 158 pp. 41-48.
25. Walsh, J, et al, 2012, Journal of Plant Nutrition and Soil Science, 175(6) pp.
840-845.
26. The World Bank, 2015, Cereal yield (kg per hectare).
27. Knight, S, et al, 2012, Desk study to evaluate contributory causes of the
current ‘yield plateau’ in wheat and oilseed rape. HGCA of the AHDB.
28. Environment Agency, 2004, State of Soils in England & Wales.
29. Northern Ireland Environment Agency, 2007, Northern Ireland Countryside
Survey 2007.
30. The Scottish Government, 2009.Scottish Soil Framework:
31. Holman, I, 2009, An estimate of peat reserves and loss in the East Anglian
Fens; Commissioned by the RSPB. Cranfield University.
32. Jaafar, M, 2010, Soil erosion, diffuse source pollution and sediment problems
associated with maize cultivation in England. University of Exeter.
33. Defra, 2012, Costs of Soil Degradation in England & Wales.
34. Natural Capital Committee, 2015, The State of Natural Capital.
35. National Audit Office, 2014, Environmental Protection.
36. Defra, 2012, Towards Sustainable Growing Media.
37. Glaser, B, 2007, Philosphical transactions of the Royal Society B, 362(1478),
pp 187–196
38. Stobart, R, and Morris, N, 2011, Aspects of Applied Biology, 113, pp. 15-24.
39. Stobart, R, and Morris, N, 2013, Aspects of Applied Biology, 121, pp. 43-50.
40. Stobart, R, and Morris N, 2014, Aspects of Applied Biology, 127, pp. 223-232.
41. West, T and Post, W, 2002, Journal of the Soil Science Society of America, 66
pp. 1930-1946.
42. Hauggaard-Neilsen, H et al, 2009, Field Crops Research, 113(1) pp. 64-71.
43. Sibbald, A 2001, Agroforestry Systems, 53 (1) pp. 39-53.
44. Gattinger, A, 2012, Proceedings of the National Academy of Sciences, 44, pp.
18226-18231.
45. Maeder, P et al, 2002, Science, 296 (5573) pp. 1694-1697
46. Martini, E, et al, 2004, Field Crops Research, 86, pp. 255-266.
47. Seufert, V, et al,. 2012, Nature 485, pp 229-232.
48. Hyland, J, et al, 2015, Agriculture and Human Values, in Press.
49. Kibblewhite, M, 2010, A gap analysis on the future requirments of soil and
water management in England. Royal Agricultural Society of England.
50. Sautter, J, et al, 2011, Society & Natural Resources, 24 (2) pp. 133-147
51. Centre of Expertise for Waters, 2012, Factors that affect uptake of natural flood
management features by farmers in Scotland: A review. James Hutton Institute.
52. NIAB, 2014, An appraisal of research, best practice and communication
approaches for the management of soil structure.
53. Demonstration Test Catchments.
54. Catchment Sensitive Farming.
55. Defra, 2011,The Natural Choice: Securing the value of nature.
56. UK Soil Observatory
57. Defra, 2011, Scoping Biological Indicators of Soil Quality Phase II.
58. Defra, 2015, Cross compliance in England: soil protection standards.
59. Northern Ireland Government, 2015, Cross Compliance.
60. Welsh Government, 2015, Cross Compliance.
61. Scottish Government, 2015, Cross Compliance.
62. Defra, 2013, Farm inspections - Guidance.
63. Defra, 2009, Safeguarding our Soils a Strategy for England.
64. DCLG, 2012, National Planning Policy Framework..
65. Defra, 2013, Payment for Ecosystem Services Action Plan.
66. IUCN, 2013, Draft UK Peatland Code.
67. Conservative Manifesto 2015.
Page 5